EN 301 549 V4.1.1 was published in September 2026. It is the finished standard now, not a draft, and its main change for the web is that clauses 9, 10 and 11 point at WCAG 2.2 instead of WCAG 2.1 (ETSI EN 301 549 V4.1.1). ETSI adopted the text on 24 August 2026.
That does not make it the legal yardstick yet. A harmonised standard gives you a presumption of conformity only once the European Commission cites it in the Official Journal of the EU (European Commission). No citation for V4.1.1 had appeared when this post was updated on 4 September 2026, so the version that counts is still v3.2.1 from March 2021, cited by Commission Implementing Decision (EU) 2021/1339, which adopts WCAG 2.1 Level A and AA.
So the position today is split. Test against WCAG 2.1 AA, because that is what the law currently points at. Add the six extra WCAG 2.2 criteria that V4.1.1 brings, because you now know exactly which ones they are.
What is EN 301 549 V4.1.1?
It is the fourth edition of EN 301 549, published jointly by ETSI, CEN and CENELEC as a Harmonised European Standard dated 2026-09. The route here ran through two drafts: v4.1.0 went out for public comment in November 2025, a final draft followed in June 2026, and V4.1.1 is the published result.
The change history annex describes the edition in one line: the entire document has been revised to become a harmonised standard for both Directive (EU) 2019/882 and Directive (EU) 2016/2102 (ETSI EN 301 549 V4.1.1). That is the structural news. V3.2.1 was prepared under a standardisation request tied to the Web Accessibility Directive. V4.1.1 was prepared under request C(2022) 6456 final to serve the European Accessibility Act as well.
You can see it in the annexes, and the earlier version of this post had them backwards. Annex ZA maps the standard to the Web Accessibility Directive, in two tables covering web pages and mobile applications. Annex ZB maps it to the EAA across five tables. A third annex, ZC, handles requirements from other directives referenced by Annex I Section VI of the EAA. There is also a new clause A.2 with five tables for evaluating a specific product or service against the EAA's essential requirements.
The standard now runs to fourteen clauses. Clause 14 covers conformance, including inoperative states and the rules for when meeting a requirement in one mode is enough.
Which WCAG version does V4.1.1 require?
WCAG 2.2. The normative reference is the W3C Recommendation of 12 December 2024, also published as ISO/IEC 40500:2025 (ETSI EN 301 549 V4.1.1). Clauses 9 (web), 10 (non-web documents) and 11 (software) all move together.
The standard spells out the delta itself, in clause 9.0, and it is the most useful paragraph in the document if you already run a WCAG 2.1 AA process. Conformance with WCAG 2.1 Level AA, it says, is equivalent to conforming with all of clauses 9.1 to 9.4 except 9.2.4.11, 9.2.5.7, 9.2.5.8, 9.3.2.6, 9.3.3.7 and 9.3.3.8. Conformance with WCAG 2.2 Level AA is equivalent to all of 9.1 to 9.4, with no exceptions.
Six clause numbers. That is the whole gap between where you are and where V4.1.1 wants you.
What are the six new criteria?
Here they are, mapped to the clause numbers above (W3C WCAG 2.2):
| Clause | Criterion | Level | What it asks for |
|---|---|---|---|
| 9.3.2.6 | 3.2.6 Consistent Help | A | If you offer help (a contact link, a chat, a phone number), it sits in the same relative place across pages |
| 9.3.3.7 | 3.3.7 Redundant Entry | A | Don't make someone re-enter information they already gave in the same process |
| 9.2.4.11 | 2.4.11 Focus Not Obscured (Minimum) | AA | A focused element is not entirely hidden behind a sticky header, cookie banner or other overlay |
| 9.2.5.7 | 2.5.7 Dragging Movements | AA | Anything that works by dragging has a single-pointer alternative, unless dragging is essential |
| 9.2.5.8 | 2.5.8 Target Size (Minimum) | AA | Interactive targets are at least 24 by 24 CSS pixels, or spaced far enough apart, with listed exceptions |
| 9.3.3.8 | 3.3.8 Accessible Authentication (Minimum) | AA | Login doesn't force a cognitive test; allow paste, a password manager, or another route |
One criterion went the other way. Clause 9.4.1.1 is now marked Void, with a note explaining that earlier versions referenced WCAG's 4.1.1 Parsing, which WCAG 2.2 removed because the problems it prevented "either no longer exist or are addressed by other criteria". The same Void appears at 10.4.1.1 for non-web documents. If your conformance report has a row for 4.1.1, that row is going away.
Target Size and Accessible Authentication are the two that surface real problems on production sites. A toolbar of 16-pixel icon buttons fails 9.2.5.8. A login form with onpaste="return false" on the password field fails 9.3.3.8, and that one attribute is usually a five-minute fix that nobody has looked at in four years.
What changed beyond the web?
Clause 6 is the big rewrite. It is now titled "ICT supporting real-time bidirectional communication", and the Real-Time Text requirements in clause 6.2 were significantly revised and extended to include total conversation, where voice, text and video run in one session (ETSI EN 301 549 V4.1.1). A new clause 6.0 sets out operational scenarios, including roaming clients and emergency calls placed from another country.
If you build a marketing site or a web app, none of that touches you. If you build calling, messaging or conferencing products, clause 6 is where your reading time goes.
What do the dates in the standard actually mean?
This is where I keep seeing people get it wrong, so here are the dates the standard prints, verbatim (ETSI EN 301 549 V4.1.1):
- Date of adoption: 24 August 2026
- Date of latest announcement (doa): 30 November 2026
- Date of latest publication of a new national standard or endorsement (dop/e): 31 May 2027
- Date of withdrawal of any conflicting national standard (dow): 31 May 2028
Every one of those is a national transposition date. They tell national standards bodies in CEN, CENELEC and ETSI member countries when to announce the standard, publish it as a national standard, and retire whatever conflicts with it. None of them is the Official Journal citation, which is a separate act by the European Commission with its own timing.
I have now read several write-ups treating 30 November 2026 as the day V4.1.1 takes legal effect. It isn't. It is the deadline for national bodies to announce the EN. The presumption of conformity arrives when the Commission publishes a citation, and the standard's own foreword says so plainly: once the document is cited in the Official Journal, compliance with the clauses in the tables in clause A.2 confers a presumption of conformity with the corresponding essential requirements. Before that citation, those tables are good engineering guidance and nothing more.
For context on how long that gap runs: v3.2.1 was published in March 2021 and the Official Journal citation followed on 11 August 2021, about five months later. That is one data point, not a rule.
What should you test today?
The legal requirement is WCAG 2.1 AA, through v3.2.1. My advice is to test the six new criteria anyway, starting now, and I would say that even if V4.1.1 had never been published. They map to bugs real people hit. Finding your undersized tap targets on your own schedule beats finding them in an audit.
A plan that survives the citation whenever it lands: keep meeting WCAG 2.1 AA, add the six checks above to your test pass, and record in your accessibility statement which version you tested against and when. Our EN 301 549 checklist walks the clause structure, and the WCAG checklist covers the full 2.2 AA set. When the citation appears, you update a version line and confirm work you already did.
One honest limit. A scanner will catch some of these and miss others. It can measure target size and flag a paste-blocked password field. It cannot judge whether your help link is in a consistent place across templates, or whether a focused button is meaningfully visible behind a sticky header. Automated testing identifies roughly 30 to 57% of issues depending on how you count, and the rest needs a person with a keyboard and a screen reader (Deque). The new criteria don't change that split.
Frequently asked questions
Is EN 301 549 V4.1.1 published?
Yes. ETSI, CEN and CENELEC published EN 301 549 V4.1.1 in September 2026, adopted on 24 August 2026. It replaces the v4.1.0 drafts from November 2025 and June 2026 as the finished text.
Does EN 301 549 V4.1.1 apply legally yet?
No. A harmonised standard confers a presumption of conformity only once the European Commission cites it in the Official Journal of the EU. No citation for V4.1.1 had appeared when this post was updated on 4 September 2026, so v3.2.1 and WCAG 2.1 AA remain the yardstick.
What does EN 301 549 V4.1.1 change for websites?
Clauses 9, 10 and 11 move from WCAG 2.1 to WCAG 2.2. For web content that means six added success criteria at Levels A and AA, and the removal of 4.1.1 Parsing, which is now marked Void at clause 9.4.1.1.
What is the difference between Annex ZA and Annex ZB?
Annex ZA maps EN 301 549 to Directive (EU) 2016/2102, the Web Accessibility Directive, in two tables for web pages and mobile applications. Annex ZB maps it to Directive (EU) 2019/882, the European Accessibility Act, across five tables covering products and services.
What happens on 30 November 2026?
That is the date of latest announcement (doa), a national transposition milestone for standards bodies in CEN, CENELEC and ETSI member countries. It is not the date V4.1.1 takes legal effect, and it is not the Official Journal citation.
Should I test WCAG 2.2 now?
Legally you don't have to, since v3.2.1 is still the cited version. It is worth adding the six new checks early, because several map to problems real users hit and it turns the eventual switch into a version-line update rather than a scramble.
Get ahead of the WCAG 2.2 baseline
The step up to WCAG 2.2 is a manageable delta if you start on the six criteria before the Official Journal citation forces the question. Run a free scan to clear the machine-detectable checks on your key pages, including target size and paste-blocked logins, then work through the manual criteria a scanner cannot judge and write down each result. You walk into the V4.1.1 transition with evidence instead of a guess.
Pavel Charkasau, founder, wcagc.com. Last updated 4 September 2026.
Sources
- EN 301 549 V4.1.1 (2026-09), ETSI/CEN/CENELEC — the published fourth edition. Cover date 2026-09; date of adoption 24 August 2026; national transposition dates doa 30 November 2026, dop/e 31 May 2027, dow 31 May 2028. Normative reference [4] is WCAG 2.2 (W3C Recommendation 12 December 2024 / ISO/IEC 40500:2025). Clause 9.0 states the WCAG 2.1 to 2.2 delta as clauses 9.2.4.11, 9.2.5.7, 9.2.5.8, 9.3.2.6, 9.3.3.7 and 9.3.3.8; clause 9.4.1.1 is Void. Clause 6 covers real-time bidirectional communication with revised Real-Time Text. Annex ZA maps to Directive (EU) 2016/2102, Annex ZB to Directive (EU) 2019/882, Annex ZC to other directives per EAA Annex I Section VI; clause A.2 adds five EAA evaluation tables. Accessed 4 September 2026.
- Commission Implementing Decision (EU) 2021/1339 of 11 August 2021, EUR-Lex — amends Implementing Decision (EU) 2018/2048 and cites EN 301 549 v3.2.1 as the harmonised standard for the Web Accessibility Directive. Accessed 4 September 2026.
- Web accessibility standards, latest changes, European Commission — a modified standard has legal significance only once it is referenced in the Official Journal; the last such change was August 2021, replacing v2.1.2 with v3.2.1. Page last updated 30 June 2025. Accessed 4 September 2026.
- Web Content Accessibility Guidelines (WCAG) 2.2, W3C — Recommendation of 5 October 2023, updated 12 December 2024; the added success criteria, their conformance levels, and the removal of 4.1.1 Parsing. Accessed 4 September 2026.
- Automated testing identifies 57% of accessibility issues, Deque — automated coverage figures across more than 2,000 audits. Accessed 4 September 2026.